Receive items from PO that has already been billed

Receive items from PO that has already been billed

Rarely manufacturers bill for items before we receive the goods, but when this occurs....

{"code":36510,"message":"The purchase order(s) have bill(s) without receive(s). Hence, you cannot add receive(s)."} 

There is no documentation on this.
Please advise on how to receive billed items via deluge woukflow actions.